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Part IVA - How’s your postulate? paper

Published on 26 Mar 14 by NATIONAL DIVISION, THE TAX INSTITUTE

This paper covers:

postulate
running cases - annihilating or reconstructing?
attempted refocusing of s.177D
new words leave 8 factors intact
words won’t fix some things
unit trend.

Author profile

David Marks QC CTA

David is a commercial Silk at the Queensland Bar, practising principally in tax. He has a broader practice in commercial litigation, trusts and estates, and administrative law. He contributes to the life of the profession through his committee work for The Tax Institute and other professional bodies. He is a Chartered Tax Adviser and a registered Trust and Estate Practitioner. He received The Tax Institute’s Meritorious Service Award in 2013. David serves on the disciplinary panel of an international practitioner association. - Current at 26 June 2019

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This was presented at 29th National Convention .

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Individual sessions

Ethical conflicts and the tax practitioner
Author(s): Gino DAL PONT

Materials from this session:

Ethical conflicts and the tax practitioner paper

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Ethical conflicts and the tax practitioner presentation

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Tax and financial reporting
Author(s): Jason de Boer

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Tax and financial reporting paper

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Tax and financial reporting presentation

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DisclaimerThese materials are copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
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Independent review and dispute resolution
Author(s): Deborah HASTINGS

Materials from this session:

Independent review and dispute resolution paper

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Independent review and dispute resolution presentation

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Alternative dispute resolution and the Australian Taxation Office
Author(s): Judy SULLIVAN

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Alternative dispute resolution and the Australian Taxation Office paper

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Independent review and dispute resolution presentation

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Restructuring – Avoiding harm’s way
Author(s): Andrew SINCLAIR

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Restructuring – Avoiding harm’s way paper

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Restructuring avoiding harm's way presentation

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DisclaimerThese materials are copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
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Strategies in business succession planning
Author(s): Matthew BURGESS, Patrick Ellwood

Materials from this session:

Strategies in business succession planning paper

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Business succession funding presentation

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DisclaimerThese materials are copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
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Structuring for the small business concessions: Getting it right from the start
Author(s): Richard J FRIEND

Materials from this session:

Structuring for the small business concessions: Getting it right from the start paper

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Structuring for the SB concessions: Getting it right from the start presentation

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DisclaimerThese materials are copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
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E-commerce, cloud and cross-border transactions
Author(s): Spyros KOTSOPOULOS, Manisha Singh

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E-commerce, cloud and cross-border transactions paper

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E-commerce, cloud and cross-border transactions presentation

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DisclaimerThese materials are copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
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Will your current approach to transfer pricing compliance meet the new legislative requirements?
Author(s): Paul BALKUS

Materials from this session:

Will your current approach to transfer pricing compliance meet the new legislative requirements? paper

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Will your current approach to transer pricing compliance meet the new legislative requirements? presentation

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DisclaimerThese materials are copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
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Recent cases
Author(s): Melanie BAKER

Materials from this session:

Recent cases paper

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Recent cases presentation

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DisclaimerThese materials are copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
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Do you (not just your clients) need to appoint a guardian as well as an attorney?
Author(s): Kate Hanslow

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Do you (not just your clients) need to appoint a guardian as well as an attorney? paper

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Do you (not just your clients) need to appoint a guardian as well as an attorney? presentation

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DisclaimerThese materials are copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
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Establishing residence in the global village
Author(s): Mary Italiano, Katya KROTOVA, Tony UNDERHILL

Materials from this session:

Establishing residence in the global village paper

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Establishing residence in the global village presentation

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DisclaimerThese materials are copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
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Division 7A structuring - The contortionist
Author(s): Ron JORGENSEN

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Division 7A structuring - The contortionist paper

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Division 7A - The Contortionist presentation

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DisclaimerThese materials are copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
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Trusts – The state of play
Author(s): Alexis KOKKINOS

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Trusts – The state of play paper

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Trusts - The state of play presentation

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DisclaimerThese materials are copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
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The penalty provisions and their administration: Living meaning or dead letter?
Author(s): Paul SOKOLOWSKI

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The penalty provisions and their administration: Living meaning or dead letter? paper

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The penalty provisions and their administration: Living meaning or dead letter? presentation

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DisclaimerThese materials are copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
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Contractor/employee – Do we still care?
Author(s): Rebecca Johnson, Brent MURPHY

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Contractor/employee – Do we still care? paper

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Employee versus contractor - Do we still care? presentation

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DisclaimerThese materials are copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
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CGT discount and non-residents
Author(s): Gordon S COOPER

Materials from this session:

CGT discount and non-residents paper

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CGT discount and non-residents presentation

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DisclaimerThese materials are copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
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Utilising flexible share rights
Author(s): John Ioannou

Materials from this session:

Utilising flexible share rights paper

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Utilising flexible share rights presentation

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DisclaimerThese materials are copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
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Director penalty notices - Extended liabilities for directors
Author(s): Barry Hamilton

Materials from this session:

Director penalty notices - Extended liabilities for directors paper

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Director penalty notice - Extended liabilities for directors presentation

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DisclaimerThese materials are copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
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Reducing de facto death duties on the payment of superannuation death benefits to adult children
Author(s): Suzanne MACKENZIE

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Reducing de facto death duties on the payment of superannuation death benefits to adult children paper

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Reducing de facto death duties presentation

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DisclaimerThese materials are copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
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Part IVA - How’s your postulate?
Author(s): David W MARKS

Materials from this session:

Part IVA - How’s your postulate? paper
(Currently Viewing)

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Part IVA – How's your postulate? presentation

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DisclaimerThese materials are copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
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Borrowing arrangements and SMSFs
Author(s): Paul BANISTER, Amy Tickle

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Borrowing arrangements and SMSFs paper

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Limited recourse borrowing arrangements presentation

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Borrowing arrangements and SMSFs video

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DisclaimerThese materials are copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
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Tax risks in acquiring an entity from a tax consolidated group
Author(s): Ian KELLOCK

Materials from this session:

Tax risks in acquiring an entity from a tax consolidated group paper

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Tax liabilities and consolidated groups presentation

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DisclaimerThese materials are copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
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Trusts and passing control – Trusts succession strategies
Author(s): Adam LEVIN

Materials from this session:

Trusts and passing control – Trusts succession strategies paper

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Trusts and passing control – Trust succession strategies presentation

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DisclaimerThese materials are copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
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GST and property transactions
Author(s): Bastian Gasser, Shoba Kanniappan

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GST and property transactions paper

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GST & property transactions presentation

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DisclaimerThese materials are copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
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Current issues with debt funding
Author(s): David ANDERSON, Tim SHERMAN

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Current issues with debt funding paper

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Current issues with debt funding presentation

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Tax deductibility of interest
Author(s): Simon STEWARD

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Tax deductibility of interest presentation

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Tax deductibility of interest video

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Commissioner's address
Author(s): Chris JORDAN

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Commissioner's address video

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Further details about this event:

29th National Convention

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Part IVA - How’s your postulate? paper

Author profile

David Marks QC CTA

More by David W MARKS

This was presented at 29th National Convention .

Individual sessions

Ethical conflicts and the tax practitioner

Materials from this session:

Ethical conflicts and the tax practitioner paper

Ethical conflicts and the tax practitioner presentation

Tax and financial reporting

Materials from this session:

Tax and financial reporting paper

Tax and financial reporting presentation

Independent review and dispute resolution

Materials from this session:

Independent review and dispute resolution paper

Independent review and dispute resolution presentation

Alternative dispute resolution and the Australian Taxation Office

Materials from this session:

Alternative dispute resolution and the Australian Taxation Office paper

Independent review and dispute resolution presentation

Restructuring – Avoiding harm’s way

Materials from this session:

Restructuring – Avoiding harm’s way paper

Restructuring avoiding harm's way presentation

Strategies in business succession planning

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Strategies in business succession planning paper

Business succession funding presentation

Structuring for the small business concessions: Getting it right from the start

Materials from this session:

Structuring for the small business concessions: Getting it right from the start paper

Structuring for the SB concessions: Getting it right from the start presentation

E-commerce, cloud and cross-border transactions

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E-commerce, cloud and cross-border transactions paper

E-commerce, cloud and cross-border transactions presentation

Will your current approach to transfer pricing compliance meet the new legislative requirements?

Materials from this session:

Will your current approach to transfer pricing compliance meet the new legislative requirements? paper

Will your current approach to transer pricing compliance meet the new legislative requirements? presentation

Recent cases

Materials from this session:

Recent cases paper

Recent cases presentation

Do you (not just your clients) need to appoint a guardian as well as an attorney?

Materials from this session:

Do you (not just your clients) need to appoint a guardian as well as an attorney? paper

Do you (not just your clients) need to appoint a guardian as well as an attorney? presentation

Establishing residence in the global village

Materials from this session:

Establishing residence in the global village paper

Establishing residence in the global village presentation

Division 7A structuring - The contortionist

Materials from this session:

Division 7A structuring - The contortionist paper

Division 7A - The Contortionist presentation

Trusts – The state of play

Materials from this session:

Trusts – The state of play paper

Trusts - The state of play presentation

The penalty provisions and their administration: Living meaning or dead letter?

Materials from this session:

The penalty provisions and their administration: Living meaning or dead letter? paper

The penalty provisions and their administration: Living meaning or dead letter? presentation

Contractor/employee – Do we still care?

Materials from this session:

Contractor/employee – Do we still care? paper

Employee versus contractor - Do we still care? presentation

CGT discount and non-residents

Materials from this session:

CGT discount and non-residents paper

CGT discount and non-residents presentation

Utilising flexible share rights

Materials from this session:

Utilising flexible share rights paper

Utilising flexible share rights presentation

Director penalty notices - Extended liabilities for directors

Materials from this session: